Case Digest (G.R. No. 207051)
Facts:
Lorenzo Willy, Substituted by His Heirs, Namely: Felicidad D. Willy, Betty Willy Cadangen, Tony Willy, Cosme Willy, Rosario Willy-Armas, Erlinda Willy-Dapyawon, Johnny Willy, Jose Willy, Rodolfo Willy, Swinie Willy, Isabel Willy, Neda Cacanando, and Benita Willy, Herein Represented by Their Attorneys-in-Fact, Maria Aprila Willy Cruz and Betty Willy Cadangen v. Remedios F. Julian, George F. Julian, Joan J. Aguirre, Emily J. Bustarde, and William F. Julian, G.R. No. 207051, December 01, 2021, Supreme Court Second Division, Hernando, J., writing for the Court.The dispute concerns a 67,635-square meter unregistered parcel at Beckel, Sto. Tomas, Tuba, Sablan, Benguet (the subject property) originally owned by Modesto Willy and appearing in tax declarations and Bureau of Lands PSU No. 192802. Modesto executed a written instrument on March 29, 1963 (the 1963 Agreement) allegedly conveying portions of the property to three persons — a surveyor, a lawyer, and an agent (Emilio Dongpaen) — in consideration of services and a modest cash amount; the instrument contemplated subdivision, titling steps and apportioned respective portions including 10,000 sq. m. to Dongpaen.
On November 16, 1968 a survey (Plan PSU-192802) identified and segregated 15,000 sq. m. as Lots 1 and 2 for the intended sale to Ricardo Julian. A sequence of conveyances followed in 1969: Dongpaen sold 10,000 sq. m. to Ricardo (Jan. 27, 1969); Dongpaen sold an additional 5,000 sq. m. to Ricardo (June 17, 1969); and Modesto executed a deed to Dongpaen for 5,000 sq. m. (June 24/25, 1969). Ricardo accepted that Lorenzo Willy (Modesto’s son) would cultivate the lots for him and remitted the fruits to Ricardo. Modesto died in 1979.
When petitioners (Modesto’s heirs) later attempted to sell the property, Ricardo asserted ownership of Lots 1 and 2 by administrative steps (Affidavit of Adverse Claim, an DAR advisory opinion) and then filed Civil Case No. 196 (Partition of Property and Damages) before the 5th Municipal Circuit Trial Court (MCTC) asserting he owned the segregated 15,000 sq. m. Petitioners denied his ownership, contending among other defenses that Modesto was illiterate and could not have signed the 1963 Agreement, that the 1963 Agreement had suspensive conditions, that the cause of action had prescribed, and that the chain of conveyances was defective because the deeds bore inconsistent dates.
The MCTC, in a September 20, 2010 Decision, found the 1963 Agreement and the 1969 deeds to be public/ancient documents and valid, held that Lots 1 and 2 were effectively conveyed to Ricardo, and ordered segregation/delivery of the 15,000 sq. m. to Ricardo plus attorney’s fees. Petitioners appealed to the Regional Trial Court, Branch 62, La Trinidad, Benguet (RTC, Civil Case No. 10-CV-2664). The RTC, in a July 12, 2011 Decision, reversed the MCTC: while accepting authenticity of some documents, it concluded the 1963 Agreement was a private document without constructive delivery, that Dongpaen had not acquired ownership when he purportedly sold to Ricardo, and that Ricardo’s remedy had prescribed; it dismissed the complaint and counterclaim and denied reconsideration (Oct. 17, 2011).
Ricardo appealed to the Court of Appeals (CA) as CA‑G.R. SP No. 122133; during the appeal Ricardo died and his heirs substituted. The CA, in a February 21, 2013 Decision, reversed the RTC and reinstated the MCTC judgment, holding that the 1963 Agreement was fully consummated, that the November 16, 1968 survey and the parties’ contemporaneous actions constituted constructive delivery to Dongpaen and, ultimately, to Ricardo, and that the MCTC had jurisdiction because the assessed value of the segregated lots was P19,100 (below the P20,000 threshold). The CA later denied petitioners’ motion for extension to file a motion for reconsideration and granted respondents’ motion for entry of judgment (April 26, 2013).
Petitioners filed a...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in denying petitioners’ motion for extension of time to file a motion for reconsideration?
- Did the MCTC properly exercise jurisdiction over Ricardo’s complaint (Civil Case No. 196)?
- Were the series of conveyances (the 1963 Agreement and the three 1969 deeds) valid and did they effect transfer of Lots 1 and 2 to Ricardo?
Ruling:
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Ratio:
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Doctrine:
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